SEC Company Response from Fidelity National Information Services, Inc. (FIS) (CIK 0001136893) (FIS) — Dec 15, 2005
Fidelity National Information Services, Inc. (FIS) (CIK 0001136893)
Date: Dec. 15, 2005 · CIK: 0001136893 · Accession: 0001104659-05-061027
AI Filing Summary & Sentiment
File numbers found in text: 001-16427
Referenced dates: December 7, 2005
Letter
Division of Corporation Finance Attention: Certegy Inc. Amendment No. 2 to Schedule 14A Filed December 14, 2005 File No. 001-16427
Dear Mr. Ossias:
Pursuant to your telephone conversation this morning with Kevin Hands of LeBoeuf, Lamb, Greene & MacRae LLP, we are writing to supplement our letter of December 14, 2005, accompanying the above-referenced filing to provide the following response to Comment No. 14 in your comment letter dated December 7, 2005.
14. We note your response to prior comment 58. Please revise the additional material sent to us to show more clearly how it supports the various rankings upon which you rely, including the: 100 largest banks; five largest captive automotive finance companies; 50 largest commercial lenders; 50 largest mortgage loan originators; 25 largest loan servicers; and 20 largest sub-prime loan servicers. Also, please provide investors with a relevant time frame for these rankings.
Response
On December 13, 2005, we sent to you under separate cover revisions to additional materials previously submitted to the staff, in response to this comment. We have also revised pages 114 and 116 of the revised proxy statement in response to your comment. In
addition, we will revise our next filing on page 116 to remove the references to the number of mortgage loan originators Fidelity National Information Services, Inc. has as customers in the U.S.
We appreciate the staff’s attention to this filing. If you have any questions or comments about the matters discussed herein, please contact Kevin Hands of Lebouef, Lamb, Greene & MacRae LLP, at (212) 424-8649, on behalf of FNF and FIS.
Very truly
yours,
KILPATRICK
STOCKTON LLP
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filename1.htm
Suite 2800 1100
Peachtree St.
Atlanta GA 30309-4530
t 404 815 6500 f 404 815 6555
www.KilpatrickStockton.com
direct dial 404
815 6175
December 15, 2005
direct fax 404
541 3276
LLedbetter@KilpatrickStockton.com
Division of Corporation
Finance
U.S. Securities and
Exchange Commission
Mail Stop 4561
100 F Street, N.E.
Washington, D.C. 20549
Attention:
Mr. Geoffrey
Ossias, Esq.
Examiner
Re:
Certegy
Inc.
Amendment
No. 2 to Schedule 14A
Filed
December 14, 2005
File
No. 001-16427
Dear Mr. Ossias:
Pursuant
to your telephone conversation this morning with Kevin Hands of LeBoeuf, Lamb,
Greene & MacRae LLP, we are writing to supplement our letter of December 14,
2005, accompanying the above-referenced filing to provide the following response
to Comment No. 14 in your comment letter dated December 7, 2005.
14. We note your
response to prior comment 58. Please
revise the additional material sent to us to show more clearly how it supports
the various rankings upon which you rely, including the: 100 largest banks;
five largest captive automotive finance companies; 50 largest commercial
lenders; 50 largest mortgage loan originators; 25 largest loan servicers; and
20 largest sub-prime loan servicers. Also,
please provide investors with a relevant time frame for these rankings.
Response
On December 13,
2005, we sent to you under separate cover revisions to additional materials
previously submitted to the staff, in response to this comment. We have also revised pages 114 and 116
of the revised proxy statement in response to your comment. In
addition, we will revise our next filing on page 116 to remove the
references to the number of mortgage loan originators Fidelity National
Information Services, Inc. has as customers in the U.S.
We appreciate the staff’s
attention to this filing. If you have
any questions or comments about the matters discussed herein, please contact
Kevin Hands of Lebouef, Lamb, Greene & MacRae LLP, at (212) 424-8649,
on behalf of FNF and FIS.
Very truly
yours,
KILPATRICK
STOCKTON LLP
/s/ Larry D.
Ledbetter
Larry D.
Ledbetter
2